ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING POLICY (AML/CFT)

1. Introduction

SpeedSellX (“SpeedSellX LLC,” based in the United States, and its subsidiaries in Brazil Apex Speedsellx Tecnologia em Pagamentos Ltda and Speedsellx Ltda) is a global platform specialized in the sale and distribution of digital and nutraceutical products, either proprietary or provided by third parties, operating in North America, Latin America, Europe, and other regions, not limited to these locations. In SpeedSellX’s business model, authorized producers can make their products available for sale, with all sales to end customers carried out by SpeedSellX as the legal seller (Merchant of Record). SpeedSellX ensures that end customers have adequate support and service channels, provided directly by the company or through authorized producers, guaranteeing that all requests are handled effectively and in accordance with applicable legislation. All payments are processed by duly licensed and regulated payment service providers in their jurisdictions. Although SpeedSellX does not process payments directly, it maintains a robust and international Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) program capable of identifying, preventing, and reporting suspicious activities, ensuring operational integrity. This Anti-Money Laundering and Counter-Terrorism Financing Policy establishes clear guidelines to ensure that the company operates under the highest international compliance standards, protecting its integrity, reputation, and relationships with affiliates, producers, partners, and end customers. This policy is an integral part of SpeedSellX’s global compliance program and must be interpreted in light of the laws and regulations applicable in the jurisdictions where it operates.

2. Policy Objectives

● Prevent the use of the platform for money laundering, terrorism financing, or other financial crimes;

● Ensure compliance with FATF/GAFI recommendations and applicable laws in all jurisdictions where SpeedSellX operates;

● Implement strong preventive, detective, and corrective controls;

● Protect SpeedSellX’s reputation and the trust of registered partners, affiliates, and producers;

● Ensure transparency and traceability of all transactions performed.

3. Scope

This policy applies to:

● Affiliates and producers registered on SpeedSellX;

● Employees, administrators, and directors;

● All transactions conducted by SpeedSellX LLC, Apex Speedsellx Tecnologia em Pagamentos Ltda, Speedsellx Ltda, and any future group entities;

● Activities conducted globally, without geographic limitation.

4. Definitions

● Money Laundering (ML): hiding or disguising the illicit origin of funds to appear legitimate.

● Terrorism Financing (TF): providing or raising funds to support terrorist activities.

● KYC (Know Your Customer): identification and verification of individuals.

● KYB (Know Your Business): identification and verification of companies (legal entities).

● PEP (Politically Exposed Person): an individual with a prominent public function, including close family and associates.

● Ultimate Beneficial Owner (UBO): the natural person who ultimately owns or controls the operation or resources.

5. Guidelines and Principles

SpeedSellX maintains zero tolerance for any misuse of its platform. It is strictly prohibited to:

● Register or maintain relationships with individuals, companies, or entities:

○ Listed in international sanctions (OFAC, UN, EU, OFSI) or national (COAF, Federal Revenue) lists;

○ Located in jurisdictions classified as high risk by FATF;

○ Involved in crimes such as fraud, corruption, drug trafficking, human trafficking, cybercrime, child exploitation, or any other illegal activity.

● Structure transactions to hide the origin, nature, or destination of funds;

● Use third parties, shell companies, or triangulated operations to mask beneficial owners;

● Make fragmented transactions (structuring/smurfing) to avoid detection;

● Any direct or indirect attempt to circumvent, facilitate, or collaborate with operations violating this policy or legal and regulatory obligations.

6. KYC/KYB and Due Diligence Procedures

6.1. Initial Collection and Verification

Before starting any business relationship with affiliates or producers registered with SpeedSellX, the company performs identity verification and risk analysis exclusively through CAF, a Brazilian company specialized in identity validation, compliance, and digital onboarding, operating with proprietary technology and holding ISO 27001 certification, following global standards of information security and data protection.

Verifications include:

● Authentication and validation of official documents, with automated analysis of multiple security features;

● Automated extraction and cross-checking of data to identify inconsistencies;

● Facial biometric verification with liveness detection and digital manipulation checks;

● Consultation of public and private databases for criminal, judicial, and financial background checks;

● Company validation, including beneficial owner identification and corporate structure analysis;

● Checks against national and international sanctions lists, Politically Exposed Persons (PEP) lists, and other applicable restrictive databases.

The process combines automated analysis and manual review for cases showing inconsistencies or risk signals. Situations classified as high risk based on objective data will result in immediate registration refusal or relationship termination, without escalation for manual review.

6.2. Enhanced Due Diligence (EDD)

Applied when:

● The registered affiliate or producer is in a high-risk jurisdiction;

● There is unusual or inconsistent transaction history;

● Inconsistencies in registration data or links to sensitive sectors are identified.

Additional measures:

● Request for proof of source of funds;

● Financial reports and bank statements;

● Formal interviews;

● Senior management approval for continuation of the relationship.

7. Continuous Monitoring

● Automated and periodic screening of affiliates and producers against sanctions and PEP lists;

● All transactions on the platform are processed exclusively by payment providers duly licensed and regulated in their jurisdictions.

● Analysis of atypical sales or commission patterns;

● Preventive blocking of accounts or payments until investigations are completed;

● Detailed recording of all incidents in secure systems with restricted access control.

8. Reporting Procedure

SpeedSellX operates under the Merchant of Record (MoR) model, assuming the position of legal seller in all transactions made through the platform. Accordingly, before customers, payment service providers, and competent authorities, SpeedSellX is formally responsible for commercial operations, even if the product sold is offered by a registered producer.

When any activity potentially constituting legal infractions, regulatory violations, or breaches of the company's internal policies involving affiliates or producers is identified, the following protocol is adopted:

1. Immediate action and internal measures

● Immediate suspension of the suspicious product or offer, with preventive blocking of financial transfers to the affiliate or registered producer;

● Preservation and recording of all relevant evidence, including promotional materials, product content, communications, transaction logs, access history, and any related technical or audit reports;

● Case classification according to severity and risk, prioritizing incidents with high regulatory, financial, or reputational impact.

2. Communication to payment service provider

● Secure and timely forwarding of all information and evidence to the payment processor (e.g., Stripe, Dlocal, etc.);

● As these providers are licensed and regulated entities, they are responsible for formally filing Suspicious Activity Reports (SARs) or equivalents with competent authorities such as FinCEN (USA), COAF (Brazil), or corresponding entities in other jurisdictions.

3. Direct communication to authorities (when applicable)

● In cases with clear evidence of criminal offenses, SpeedSellX may, at its discretion or by legal obligation, communicate directly to police, prosecutorial, or judicial authorities regardless of the payment provider’s report;

● In Brazil, such communications may include, but are not limited to, Civil Police, Federal Police, and Public Prosecutor’s Office. In foreign jurisdictions, communication will be directed to the relevant local authorities.

4. Assignment of responsibilities

● As Merchant of Record, SpeedSellX assumes initial responsibility before customers, payment partners, and authorities;

● However, the involved affiliate or producer will be held civilly, administratively, and criminally liable for illicit conduct, as provided in Terms of Use, commercial contracts, and other platform policies;

● SpeedSellX reserves the right to take legal action for damages, block funds, and enforce contractual guarantees.

9. Training, Awareness, and Compliance Culture

● Mandatory training for all employees, covering operational, marketing, support, management, and technology development teams, with content adapted to each

area’s responsibilities;

● Specific modules on AML/CFT, sanctions, and global compliance;

● Practical simulations and case studies;

● Formal registration of participation and performance evaluation;

● Immediate training for new employees.

10. Audit and Review

● Annual review of this policy by the Compliance area;

● Periodic internal or external audits to ensure effective implementation;

● Immediate adjustments in case of failures or regulatory changes.

11. Record Retention

● All KYC/KYB records, monitoring data, and reports of suspicious activities will be kept for a minimum of 5 years after termination of the relationship;

● Secure storage with encryption and restricted access control.

12. Final Provisions

This policy must be read in conjunction with SpeedSellX’s Sanctions Compliance Policy. Both are mandatory for all internal employees and must be observed by affiliates and registered producers as a condition for platform use.

Contact for questions or reports: compliance@speedsellx.com